Northeast Johnson County morning roundup

first_imgSM East student body president Morgan Twibell’s selfie from the podium at graduation Wednesday. The district is putting its telecasts of the graduation ceremonies online.SM East wins Sunflower League golf title. SM East’s golf team put a cap on another Sunflower League title Wednesday with a strong showing at the Lawrence Invitational at Alvamar Golf Course. Though the Lancers finished second in the tournament team standings behind Washburn Rural, their 305 on the day was enough for them to easily secure their ninth straight league title. SM East’s Andy Spencer finished first in the individual standings Wednesday with a 69, and also took first place in the individual league standings. SM East actually capture the top three individual spots in the Sunflower League, with Lucas Jones and Worth Blackman finishing second and third overall, respectively. SM East’s Johnnie Norton finessed eighth overall in the individual standings. SM East will compete in regionals play Monday at Deer Creek Golf Club.Video of SMSD graduation ceremonies available online. If you missed SM North’s or SM East’s graduation ceremonies earlier this week and want to watch a loved one or friend walk across the stage, you’re in luck: the district has posted its telecasts of all the district’s graduation ceremonies online. You can check them out here.TV can’t get enough of the PV Happy Tree. Yesterday we published a link to Fox 4’s story on the “Happy Tree” by the Oxford Fountain island in Prairie Village. Whelp, KMBC liked the idea as well, and did their own piece on it. As far as Happy Tree stories go, this one is pretty solid. [Happy Tree brings smiles to people in Prairie Village park — KMBC]Roeland Park to start sealing streets. Roeland Park will begin a program of sealing cracks on city streets in the next week. The work is anticipated to last two to three weeks. Roeland Park began its crack sealing program last year. Crews use a form of rubberized asphalt to fill small cracks in the street surface to prevent water from seeping in and causing premature damage to the road’s substructure. An overview of the process is available here.SM North grad earns NCAA postgraduate scholarship. Luke Calkins, a 2010 SM North graduate who went on to dive for the University of California San Diego, has earned an NCAA postgraduate scholarship. Calkins is a two-time Capital One Academic All-American and this season earned College Swimming Coaches Association of America (CSCAA) All-America status. He maintained a 3.94 grade point average in mechanical engineering. Just 174 collegiate athletes from across the country —87 males and 87 females — receive NCAA postgraduate scholarships. Calkins plans to work for Cymer, a Southern California company, for a year or two before attending graduate school. His father, John Calkins, was a collegiate fencer at Princeton. His mother Mary is a University of Kansas graduate.last_img read more

Justice rumbles on

first_imgObiter confesses to being a bit of a grouch when the tummy is rumbling, but it seems he is not the only one. This fascinating graph supplied to Obiter by science journalist Ed Yong reveals an interesting relationship between the grant of parole and the time of day. Compiled by academic Shai Danziger from Ben-Gurion University of the Negev, and based on 1,100 parole hearings in Israel over a year (40% of the total during that time), the vertical axis shows the proportion of hearings where parole was granted, while the horizontal axis shows the time of the hearings during the day. The two dotted lines are the points where the judges went on a snack and lunch break. So the odds that prisoners will be successfully paroled start off fairly high at around 65%, and plummet to nothing over a few hours, until they rise again after break time. It seems justice is served, but more so after lunch is served. See Ed Yong’s blog.last_img read more

Saudi Railway Polytechnic established

first_imgSAUDI ARABIA: Last year TQ Education & Training was awarded a five-year contract to provide training and management services to the Saudi Railway Polytechnic, which has been established in Buraydah through a partnership between Saudi Arabia Railways and Technical & Vocational Training Corp.TQ is responsible for developing the curriculum and learning materials, managing equipment and facilities and employing the training staff. The polytechnic will train 1500 students aged 18-21 years over five years, providing vocational qualifications in health & safety, mechanical, electrical and civil engineering, signalling & telecommunications, rolling stock maintenance and train driving. All teaching will be in English. As well as Saudi nationals, it is hoped that the polytechnic will attract students from across the region.nlast_img read more

Umemura reaches Ogimura semis

first_img GET THE BEST OF THE JAPAN TIMES IN FIVE EASY PIECES WITH TAKE 5 Aya Umemura edged fellow Japanese An Konishi 4-3 to reach the women’s semifinals of the Ogimura Cup table tennis tournament on Saturday, while teenage phenom Ai Fukuhara’s competition ended after losing her doubles match.Umemura won 11-7, 11-2, 6-11, 10-12, 9-11, 11-9, 11-6 to become the only Japanese surviving in the singles draw, joining Wang Shan of China, Kim Kyung Ah of South Korea and Romanian Mihaela Steff in the last four.center_img Wang ousted Japan’s Ai Fujinuma 4-2 while Kim came from two games down to down Olga Nemes of Germany 4-2. Steff cruised past South Korea’s Kim Bok Rae 4-0.The 13-year-old Fukuhara, who has been named to the Japanese team for the upcoming Asian Games in South Korea, and Konishi lost 4-3 to the German pair of Nemes and Nikole Struse in the women’s doubles quarterfinals.In the men’s singles, Zoran Primorac (Croatia), Karlinikos Kreanga (Greece), Chuan Chih-yuan (Taiwan) and Qiu Yuke (China) advanced to the semifinals. last_img read more

President of GPA David Collins Speaks To Over The Line

first_img Galway Bay FM Sport President of GPA David Collins Speaks To Over The Line Forward 60 seconds David has been speaking to Gerry Murphy President of GPA David Collins Speaks To Over The Line Forward 60 seconds Galway Bay FM Sport Former Galway Hurler David Collins was recently elected as President of The Gaelic Players Association. Back 15 seconds Back 15 seconds 更多 President of GPA David Collins Speaks To Over The Line Currently Playing He replaces Dermot Earley who has become the association’s Chief Executive. Galway Bay FM Sport print WhatsApp Facebook Twitter Emaillast_img read more

Stephen F. Austin’s Rally Falls Short in NCAA Second Round

first_img But SFA once again showed why it has won 61 games over the past two years as the Lumberjacks began chopping away at that deficit. The `Jacks were paced by a key three-pointer from Charles, some timely turnovers, free throws and an authoritative block by Walkup on All-American Delon Wright, pulling to within four at 44-40 with six minutes to go, setting up a frantic finish. Utah responded by building a six-point lead at the midway mark of the opening half at 16-10, answered by a three from Charles and a jumper from Walkup to cut the deficit back to one at 16-15. In a game that played out as a defensive slugfest from the get-go, Utah built an early 4-0 lead, which was quickly answered by a three from Charles, cutting the gap to one. SFA then took its sole lead of the night off a jumper from Parker, leading 5-4 with 15:00 remaining in the opening half. “We just didn’t hit the shots we needed to hit tonight,” said head coach Brad Underwood. “You have those nights where shots just aren’t falling, and tonight was one of those nights for us. But it shouldn’t overshadow what a tremendous year this team has had. I can’t say enough about how proud I am of this team and what they accomplished.” Dallas Cameron and Jacob Parker each finished with six points as Parker struggled in what is normally one of his strengths, going 0-for-8 from beyond the arc. Demetrious Floyd finished with five points while Trey Pinkney dished out three assists, finishing with three points on the night. SFA now sets its sights on the 2015-16 season and a defense of its three-straight Southland Conference titles. The Lumberjacks return four of its starting five, as well as a handful of other key returners. Freshman Ty Charles gave SFA fans a great deal of optimism, finishing with a team-high 14 points, hitting four of his eight three-point attempts, while adding seven rebounds. Thomas Walkup came up just shy of his third-straight NCAA tournament double-double, finishing with 12 points and nine rebounds with five assists. However, SFA’s shooting woes struck once again as the `Jacks were unable to hit the key shot down the stretch and Utah’s free throw shooting put the game away. SFA upped its intensity early in the second half as a pair of free throws by Cameron, a layup by Pinkney and a driving dunk by Parker once again pulled SFA to within one at 26-25 three minutes into the half. PORTLAND, Ore. – Stephen F. Austin had itself poised for another memorable NCAA tournament comeback, trailing fifth-seeded Utah by two with less than a minute to play. But the Lumberjacks couldn’t get the key shots to fall when it counted, falling to the Utes 57-50 in the second round of the NCAA tournament at the Moda Center.center_img 2015 NCAA Second Round Utah 57, Stephen F. Austin 50 Moda Center • Portland, Ore. Records: SFA (29-5); Utah (25-8) After Utah went back on top by four at 48-40, SFA and the Utes exchanged blows over the final five minutes. Trailing 52-46 with a minute and a half to go, Charles banked in a three from the top of the key. Walkup then forced a turnover and Pinkney hit one of two free throws to trail by just two at 52-50 with 40 seconds remaining. SFA closes out another memorable season at 29-5, coming one victory shy of notching back-to-back 30-win seasons. But the shooting drought once again clipped the `Jacks as SFA managed just two field goals over the next 10 minutes with a pair of free throws as Utah used a 17-6 run, building its largest lead of the night at 43-31 with just over nine minutes to play. A key stretch in the contest then came over the next seven minutes as the Lumberjacks were held without a basket while Utah rattled off a 10-0 run, building an 11-point lead at 26-15 with a minute to play. Momentum started to swing back in SFA’s favor, thanks to back-to-back dunks by Tanner Clayton in Parker in the waning seconds, trimming the Ute lead to 26-19 at the half. The 50 points marked SFA’s lowest output of the season, one point shy of the 51 points its registered in the loss at Baylor in November. The loss to Utah also marks the third-straight year a Pac-12 team has ended the Lumberjacks’ season, falling to Stanford in the 2013 NIT and UCLA in the 2014 NCAA tournament. The loss brought to an end the storied career of senior Jacob Parker, who finishes his career ranked 15th in program history in scoring and 12th in rebounding, establishing his place as the all-time winningest Lumberjack in Division I history. SFA shot just 33.3 percent for the game, hitting just 17 of its 51 shots, and was a mere 19.2 percent from beyond the arc, making five of its 26 attempts. Contrast that with Utah which hit 47.4 percent of its shots and 38.5 percent of its threes.last_img

Sylva Man Charged with Child Rape

first_imgBilly Joe Young, 54, of Snowdrift Lane, is charged with felony first-degree rape of a child, felony child sex offense, and six counts of indecent liberties with a child. Young is in jail on $600,000 bond.His next court date is April 12, 2017.Young has a record dating back to 1990 when was convicted in Macon County of a felony Indecent Liberty with a Child and a Felony Crime Against Nature.last_img

Columbus Catholic girls basketball loses at Neillsville

first_imgDons fall to 8-11By Paul LeckerSports ReporterNEILLSVILLE — Columbus Catholic was held to 24 percent shooting and dropped a 53-37 decision to Neillsville in a Cloverbelt Conference East Division girls basketball game Tuesday night at Neillsville High School.Abby Baierl scored 14 points for the Dons, who drop to 8-11 overall and 5-9 in the Cloverbelt East. Columbus made just 10 of 41 shots from the field and was only 10 of 19 at the free throw line in the loss.Kayla Lis had 14 points, and Danielle Pfeiffer added 13 for Neillsville, which is now 15-3 and 11-2 in the Cloverbelt East.The Dons hung close, trailing by eight at halftime, before Neillsville outscored them 27-19 in the second half.Columbus Catholic is at Colby on Friday.(Hub City Times Sports Reporter Paul Lecker is also the publisher of MarshfieldAreaSports.com.)Warriors 53, Dons 37Columbus Catholic 18 19 – 37Neillsville 26 27 – 53COLUMBUS CATHOLIC (37): Morgan Albrecht 1-5 0-2 3, Baylie Neider 0-7 5-6 5, Maren Seefluth 1-4 2-4 4, Kendra Baierl 0-1 0-0 0, Jessica Trad 0-5 1-2 1, Abby Baierl 5-12 0-2 14, Natalie Pospyhalla 2-6 0-0 6, Sierra Litwatis 0-0 0-0 0, Marissa Immerfall 1-1 2-3 4. FG: 10-41. FT: 10-19. 3-pointers: 7-19 (A. Baierl 4-9, Pospyhalla 2-6, Albrecht 1-1, Neider 0-1, Trad 0-2). Record: 8-11, 5-9 Cloverbelt East.NEILLSVILLE (53): Mindy Schoengarth 3-9 0-0 8, Morgan Hauge 1-3 0-0 3, Kayla Lis 6-15 0-0 14, Danielle Pfeiffer 4-10 3-4 13, Samantha Cappadora 1-2 0-3 2, Ashlee Diestler 2-5 0-0 6, Lexi Opelt 0-1 0-0 0, Laren Mesar 3-6 1-2 7, Grace King 0-1 0-0 0. FG: 20-52. FT: 4-9. 3-pointers: 9-19 (Pfeiffer 2-3, Diestler 2-3, Schoengarth 2-4, Lis 2-6, Hauge 1-3). Record: 15-3, 11-2 Cloverbelt East.last_img read more

Plesk VPS Hosting For Better Website Outcomes

first_img Plesk is a universally user-friendly platform. (Image source: Large preview)In all honesty, I don’t know how much time your clients will spend inside the control panel. When I’ve managed and built websites for clients in the past, just asking for login credentials to their hosting account tended to be a real chore.“What’s hosting? Is that WordPress? I don’t think I need that.”Regardless of whether they want or know what to do with a control panel, Plesk provides a user-friendly experience regardless of who the user is as well as their level of comfort with website management. I’ll show you why in this next example.Words cannot describe how frustrating it is to ask clients to complete simple tasks. (Source)Great Interface For Clients And Other End UsersIf you’ve ever tried to use cPanel to manage hosting and domain services, you know how overwhelming it can be to use.If you’re not familiar with it, this is typically what cPanel looks like upon first logging in: Plesk VPS Hosting For Better Website OutcomesYou are here: Related postsInclusive Components: Book Reviews And Accessibility Resources13th December 2019Should Your Portfolio Site Be A PWA?12th December 2019Building A CSS Layout: Live Stream With Rachel Andrew10th December 2019Struggling To Get A Handle On Traffic Surges10th December 2019How To Design Profitable Sales Funnels On Mobile6th December 2019How To Build A Real-Time Multiplayer Virtual Reality Game (Part 2)5th December 2019 A look at the Plesk service provider interface for developers. (Source: Plesk) (Large preview)It looks a lot like the power user view, except you can see that the sidebar is broken up into different modules. What I like about this is that it encourages developers to manage more of their business from one tool instead of a variety of business management tools.From within Plesk, you can:Add new customer accounts and manage them from one dashboard. HomeWeb DesignPlesk VPS Hosting For Better Website Outcomes cPanel’s user interface (Image source: cPanel) (Large preview)There’s a navigation and sub-navigation bar at the top, which makes management options seem simple enough.Then, you’re presented with individual actions you can take to manage hosting, your website or email accounts within the control panel itself. This is just too much — even for technically-minded clients who know what the heck they’re looking for.Now, check out the Plesk interface for power users: Managing customers in Plesk is easy. (Source: Plesk) (Large preview)Create hosting plans that you can, in turn, sell to customers as subscriptions. This is how the cPanel interface (meant for end users) looks like. (Image source: cPanel) (Large preview)If you plan on reselling or managing hosting for your cPanel clients, then you’ll need to use a separate dashboard called WHM: Adding and managing customers in Plesk is easy. (Source: Plesk) (Large preview)Customize what they do and see in their “power user” view of Plesk. This helps keep server and website management under control. Large previewIt won’t take long to realize that Plesk is not like other control panel solutions. The website will help clarify some of this for you, but I’d like to give you an inside look at the control panel so you can see for yourself.A Universally Friendly Control PanelPlesk is one of those tools you step inside of and immediately realize you made the right choice. With a very short learning curve, Plesk is a highly intuitive control panel solution that’s great for anyone: It’s easy to configure your server with Plesk. (Source: Plesk) (Large preview)Manage the essentials to ensure the server runs in tip-top shape. For instance, here are some of the PHP settings for security and performance: Plesk users can control various WordPress settings and tools inside of the control panel. (Source: Plesk) (Large preview)If you’ve ever been frustrated with the management piece of your business or felt that your ability to control things was lacking, Plesk is the solution. Plus, you can use Plesk extensions to really open this tool up. Add business management features like invoicing and site-builder tools to improve your offering, streamline your workflow and make more money.Last but not least, you can white label it with your branding. That way, when clients step inside, they’re reminded that they have a trusted website pro like you to properly manage their server and website.Flexible WorkflowsAnother developer-friendly feature of Plesk is its flexibility.One of the issues with letting clients make decisions about their web hosting and server management is that they don’t understand the amount of work that goes into it behind the scenes. They might think:“You’re the developer. Why can’t you work with whatever I give you?”But you and I know it’s not that simple.For starters, there’s your level of comfort in using the command line. For some developers, that level of comfort is low, so having a flexible solution like Plesk that removes the need for programming is great.That said, you can still use the CLI if you prefer. Plesk provides you with full root access, so you won’t have to worry about being restricted to the control panel’s settings to manage your VPS server either. Like I said, it’s flexible. It allows you to work as you want to work.Plus, it works on a number of configurations:Linux vs. WindowsApache vs. nginxRuby on Rails vs. Node.js.Whatever you choose, settings are available to deeply customize and configure each so that the VPS hosting plan works exactly as you need it to.Wrapping UpIt’s your hope that when you build a website for a client, it doesn’t go to waste. You design powerful website experiences so that clients can effectively leverage their web presences to drum up new business and increase conversions.Sadly, something like a poor choice of web hosting can compromise all of that planning and hard work on your part. Unless you’re in the habit of designing websites for very small businesses or nonprofits, Plesk VPS Hosting is the logical choice. Not only is it a great solution in terms of easing your administration and management responsibilities, but it’s also an amazing tool for building your design business.If you’re interested in using Plesk VPS hosting, I’d suggest you start by looking at HostGator. In addition to being one of the leading hosting companies around the world, there is a 45-day Money-Back Guarantee available which may help you encourage your clients to give it a try. (ms, ra, yk, il)From our sponsors: Plesk VPS Hosting For Better Website Outcomes The Plesk power user home page. (Source: Plesk) (Large preview)This is insanely well-organized and clearly labeled. If your clients or other novice users were to step inside of Plesk, they’d instantly know where to go as well as which actions they could possibly take from the sidebar alone.It gets better within each of the individual modules. For instance: An example of the clean layout of the Plesk UI. (Source: Plesk) (Large preview)This is what the Tools & Settings page looks like. As you can see, it’s not bogged down by a barrage of icons for each setting. Instead, it presents options in a succinct and well-organized manner, which will greatly reduce friction that might otherwise exist in a tool of this nature.Great Interface For Designers And DevelopersPlesk offers an alternative “service provider” view for web developers and designers: Security and performance controls are a priority in Plesk. (Source: Plesk) (Large preview)Manage things like plugins, themes and more if you build websites with WordPress. Plesk VPS Hosting For Better Website Outcomes Plesk VPS Hosting For Better Website Outcomes Suzanne Scacca 2019-03-28T10:30:39+01:00 2019-03-28T12:16:29+00:00(This is a sponsored article.) In early discussions you have with clients about the website you’re tasked with designing, does the topic of web hosting ever come up? My guess is that it’s not something your clients give much thought to, waving it away with:“Just give me the cheapest, no-frills hosting.”I get why they’d think that way. For starters, they’re paying you a large sum of money to design the site. Of course, they’re going to look to other areas to offset those costs. Because server technology is rarely understood by the people who own websites, it’s easy for them to mistakenly think they can save money there.Here’s the problem though:As a website grows in authority and expands its reach, security and performance problems will arise if the hosting configuration isn’t prepared to handle it.In the following article, I’m going to show you why clients need the power of VPS hosting behind the websites you design for them. And why you — the administrator — need a tool like the Plesk control panel to manage it.The Web Designer’s Connection to Web HostingIn many cases, people get stuck being the go-to person for one highly specialized task at the companies they work for. This person handles the marketing. This person manages inventory. This person coordinates client meetings.One of the things I love about working with websites is that there are so many new things to learn about and other areas to branch out to. If you don’t want to be relegated to building website after website, day in and day out, there are ways to expand your offering and become the total end-to-end solution provider for clients.In my opinion, web hosting is one of the areas you should look to for expansion. Now, I’m not saying you should become a reseller of hosting or anything like that. All I mean is that it would be beneficial to understand how the technology behind a website affects the outcomes of what you’ve built.For example:An underpowered hosting plan fails to handle influxes of traffic, which leads to slower page speeds and a drop in conversion rates.Occasional downtime on the website leaves visitors wondering if it’s even worth going to the site if its availability is unreliable.There’s a high demand for the inventory sold on the site, but potential customers are too nervous to pull the trigger since security seems to be non-existent.Even if you’re not the one responsible for the server technology your client’s site sits on, you can see how this sort of thing could have a negative effect on your business. You build an amazing website that aims to do exactly what your client wanted, but the server technology is holding it back.Who do you think the client is going to blame in that case?Rather than let it get that far, I’d suggest you engage your clients early on in conversations about their web hosting. As we move on, I’m going to present you with specific arguments you should be prepared to make regarding the hosting as well as how it’s managed.An Introduction To VPS HostingWhen it comes to choosing the right hosting for your clients’ websites, there’s a lot to think about:Who Should You Entrust Your Website To?There are thousands of web hosting companies to choose from. But in terms of reliability? That list could easily be narrowed down to less than a hundred.HostGator has been a web hosting company I’ve recommended to clients for years, especially ones who need a powerful hosting solution like Plesk VPS hosting. If your client doesn’t have a strong preference of provider, start here.What Type Of Web Hosting Will Serve Your Website And Audience Best?This is what you need to know about the different kinds of web hosting:Shared HostingThis is the cheapest form of hosting available and probably the one your clients will be most inclined to purchase.The hosting provider designates a section of a web server to a number of clients who will then share the resources. This means there are strict limitations set on how much bandwidth and storage a website can use, but very little you can do to control any of it — especially if another website in the shared server space hogs the resources.It’s this last point that’s especially problematic on shared hosting. Although your hosting plan might indicate you get X amount of memory, it’s actually a cap on how much you might have access to if no one else is using resources from the server at the same time. In reality, it’s very likely you’ll run into lack of memory errors due to this limitation quite frequently.Shared hosting is fine for small, personal blogs or private websites. Not for serious businesses.Cloud HostingThis is similar to shared hosting except that it’s more secure and stable.Rather than relegate a website to one specific segment of a web server, the site is hosted across a number of servers. That way, if one server experiences an outage or another website compromises the performance of others around it, your website can safely be hosted elsewhere.That said, there are still a number of limitations that come from cloud hosting. If your website is for a growing business, but you don’t expect a lot of traffic to it (say, if it were a simple portfolio), cloud hosting would be a good choice.Dedicated HostingThis is the most robust form of web hosting, which also makes it the most expensive.As the name indicates, your hosting company will lease you an entire server to host your website. So, think of this like shared hosting, but on steroids. As you can imagine, when you have your own server environment, it greatly reduces the risk of anyone else compromising the performance of your website.That said, there is a lot more work involved in managed a dedicated hosting account and the website on it. This is really only best for large enterprises, social networks, e-commerce sites and others that require this type of extreme web hosting.VPS HostingThis stands for “virtual private server”. The name alone should give you a good idea of how this differs from the other kinds of hosting already mentioned.In sum, a virtual private server is like a scaled-back version of dedicated hosting. Instead of having an entire server to yourself, the web hosting company carves out a dedicated portion of the server and personalizes its settings for you. Although you share the server with other VPS clients, you don’t share the resources with anyone else. You get exactly what you pay for.Here are some other highlights of VPS hosting:It’s faster and more secure than shared or cloud hosting.It’s cheaper than dedicated hosting.It’s custom-tailored to your needs, but still allows you to take more control over your server configuration.Bottom line: VPS is an overall better hosting solution for growing businesses.How Will You Manage Your Web Hosting Account?There’s one more question you have to ask yourself before you commit to a new hosting provider and plan.Because VPS hosting is more complex and requires a greater degree of management than a set-it-and-forget-it type of hosting like shared or cloud, you need a control panel you can rely on.So, let’s explore the Plesk panel and take a look at what you can do to maximize the management of your new website with it.An Exploration Of Plesk VPS HostingThis is the Plesk website: Posted on 28th March 2019Web Design FacebookshareTwittertweetGoogle+share Managing hosting plans in Plesk is easy. (Source: Plesk) (Large preview)Move non-Plesk customers over to Plesk with a simple-to-use migration tool. The Plesk Migrator extension. (Source: Plesk) (Large preview)Customize nearly every aspect of your clients’ server configurations. Like disk space:last_img read more

Extraterritorial Income Transition Rule Allowed Continued Benefits (DWA Holdings LLC, CA-FC)

first_imgAn animated film company could receive tax benefits for transactions entered into in 2005 and 2006 under the extraterritorial income transition rule. The transition rule provided reduced ETI benefits for years 2005 and 2006, as part of the ETI regime repeal. Therefore, the Claims Court erred in holding that the transition rule did not apply to income recognized after 2006 under the taxpayer’s long-term distribution contract. Rather, the statute applied transitional relief to ETI generated from transactions entered into in 2005 and 2006. It did not matter when the income was recognized.Extraterritorial Income Transition RuleThe ETI transition rule took a transaction, rather than income-based approach, in providing transitional relief. The plain language of the statute provided decreased benefits for transactions entered into in 2005 and 2006. The statute used the word “transaction” and made no reference to income earned during those years. Also, under the last antecedent canon of statutory construction the word transaction, not income, preceded the phrase “during 2005 or 2006.”Also, other ETI repeal provisions of the AJCA adopted a transaction-based approach. In contrast, the transitional rule for the tax benefit for domestic production activities, which replaced the ETI regime, employed an income-recognition approach. This indicated that Congress was aware of, and intended to use, different approaches. Additionally, the IRS’s continued use of Form 8873, Extraterritorial Income Exclusion, for taxpayers to claim transitional benefits for transactions entered into before December 31, 2004, supported the transaction-based approach. Although the form related to a different ETI transition rule, the form had not been obsoleted. Moreover, it was not plausible that Congress employed a transaction-based approach for one rule and an income-based approach for another.Reversing and remanding a FedCl decision, 2016-2 ustc ¶50,433. Login to read more tax news on CCH® AnswerConnect or CCH® Intelliconnect®.Not a subscriber? Sign up for a free trial or contact us for a representative.last_img read more